September 4, 2008
I help independent life insurance agents make the best recommendations for their clients' safe money. Indexed annuities have become an important part in the planning process for many insurance agents, whether they hold a securities license or not.
If these products become regulated as securities, many clients will likely miss the opportunity to participate in the upside potential of an indexed annuity without the risk of direct market involvement. Instead, they will likely find their way into fixed rate products without any upside potential. Many of these clients have built strong relationships with their trusted agents, and will still take their recommendations. It is not fair to take this opportunity off the table for so many clients in our presently strained economic environment.
These products are essential to the livelihood of many agents, who are focused on safe strategies. Many of my non-securities licensed agents enjoy their position of offering only products with guarantees. These same agents are also not interested in offering securities products that expose their clients to market risk.
Indexed annuities are fixed annuities. They have guarantees. I urge the SEC to not regualte them as securities and let the states' DOI determine whether or not a product meets the definition of a fixed product and to approve only quality annuity products.
Thanks for your consideration.
Paul Irving